ML17354A256

Post-Fire Safe Shutdown Capability, Technical Evaluation Rept

ML17354A256
Person / Time
Site:	Turkey Point
Issue date:	02/14/1983
From:	Macdougall E, Thomas H BROOKHAVEN NATIONAL LABORATORY
To:	NRC
Shared Package
ML17354A254	List: ML17354A256
References
NUDOCS 8303020207
Download: ML17354A256 (23)

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POST FIRE SHUTDOWN CAPABILITY TURKEY POINT UNITS 3 AHD 4 BNL Reviewers - H.J. Thomas and E.A. NacDougal,l

1.0 INTRODUCTION

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The Turkey Point Units 3K4 Appendix R review, transmitted by Florida Power and Light's July 1, 1982 letter, outlines the licensee's fire protection involve-ment dating back to their Harch 1977 fire hazards analysis. Included in the report is the licensee's response to the NRC's generic letter 81-12 dated February 20, 1981 and the subsequent clarification letter dated Hay 10, 1982.

A telephone conference was held with representatives of NRC, FPEL and BHL on August 17, 1982 to discuss aspects of the submittal (Appendix A).

The licensee's submittal supports requests for exemptions from Appendix R based on analyses. Since the task of reviewing and. prepari ng recommendations..

f v) ex<'",+t1 ons on thi 5 bali s i s not wi thi n the scope of wet k assi gned to Brookhave>> National Laboratory, the following commentary does not constitute a r ec"..mendation for or aoainst their proposals. It is ielt that the comments provided herein might be useful in assisti ng the NRC in making a determination in this case.

The submi ttals which were reviewed are as follows:

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1. Fire Protection Report for Turkey Point Plant Unit Nos. 3 and 4, July 1, 1982.

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2. Fire Protection SER - 3.2.4 Auxiliary Building Hallway and 3.2.5 Cabl'e Spreading Area, April 2, 1982.

3. Request for exemptions from certain requirements of 10 CFR - 50.48 and Appendix R to CFR Part 50, Harch 19, 1981.

4. Response to staff summary of requirements to resolve "open items",

February 4, 1981.

5. Safe Shutdown Evaluations for the auxiliary building hallway and cable spreading room, June 9, 1980.

1.2 Fire Protection SER Position Section 4. 1 of the SER, Safe Shutdown Systems, states that the licensee has demonstrated in most areas of the plant, an unmitigated fire would not threaten the capability to achieve safe shutdown with the exception of areas i denti ie" in Sections 3. 2.4 Auxiliary Buildi no Corridor and 3.2.5 Cable Spreading Area.

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1.3 Plani Descri tion ~

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Turkey Point Units 354 are twin Westinghouse PWR plants rat'ed at 728 HWe.

Unit 3 went into operation in December 1972 and Unit 4 in September 1973.

They are owned and operated by the Florida Power 8 Light Company. Two ad-ditional oil fired units are availab'le at the Turkey Point site.

2. 0 REY I EW AUD EYALUATION 2.1 Section III.G - Fire Protection Shutdown Capabilit 2.1.1 S stems Used for Post Fire Safe Shutdown Reac'ivity cortrol is accomplished by control rod insertion and boric acid injection by the charging pumps which take their suction from the boric acid storage tanks v'.a the boric acid transfer pumps. A secondary boration'method is 5".ra".ed watei injenion from the refueling water stol age tank via gl avity feed direct'ly to the charging pumps. A cross tie to the Units 384 charging pump discharge piping is installed.

Reactor coolan systems mal eup is achieved by the use of any of three charging pumps taki ng suction from the refueling water storage tank. Other sources of reac.or cooling system makeup are the primary water storage .tanks or the spent fuel pools.

Decay heat removal is accomplished through the steam generators by throttling the condensate/feedwater back to the system generator no load condition with steam relief to the condenser via four turbine bypass valves. Should the turbi ne bypass, condenser vacuum or condensate/feedwater pumps be unavailable, steam generator heat removal is maintained by the auxiliary feedwater system with steam relief via the three atmospheric dump valves (located upstream of their respective main steam isolation valves).

Auxiliary feedwater is .provi'ded by three turbine driven auxiliary feedwater pumps. A manual cross tie to the Units 3 and 4 main steam header and a manual crosstie to the fossi l Unit 1 and 2 desuperheater steam header are available to s.pply the auxiliary feedwater pump turbines. The. auxiliary feedwater pumps are normally aligned to take suction from the Unit 3 and 4 Condensate Storage Tank. Additional condensate is available frbm the water,'treatment plant or the primary water storage tank.

ResiCual heat is removed by redundant trai ns of residual. heat removal (RHR),

component cooling water (CCW), and intake cooling water ( ICW) equipment. A cross tie to the Units 364 CCW discharge piping is installed.

Reactor pressure control is achieved by use of redundant trai ns of heaters. The backup heaters can be loaded on to the two emergency pres-'uri:er diesels.

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Process monitoring is provided for the following parameters at areas remote to.

the control room: IL

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PARAMETERS LOCATION Pressurizer pressure and level Charging pump room panel Reactor coolant cold and hot leg temperatures Unknown Steam generator pressure and temperature Auxi 1 i a ry feedwater control station Auxiliary feedwater flow Auxi 1 i ary feedwater control station

'.Bori c aci d tank 1 evel s Unknown Refueling water tank levels Unknown No source range flux monitoring is available remote to the control room.

Hechanical support systems required for hot and col.d shutdown are as fellows:.

Ca-,ponent Cooling 1/ater, Int'ake Cooling hater, Diesel Generators, and HVAC for Containnent, Auxiliary Building and Control Room.

Electrical systems used for safe shutdown are the 4;16KV, 480V, 120Y AC and the 125 Y DC Distribution Systems.

2. 1.2 Type of Fire Protection Provided The licensee has divided the plant into one hundred and thi rty-two fire areas.

The licensee proposes to make backfit modifications to comply with Section III.G of Appendix R to thirty-four (34) fire areas. They are however, making schedule exemption requests to provide desired time to complete the modifica-tions. The type of modifications which are embodied in the following:

Protect one train of shutdown (SD) cables utilizing thermal insulation wrap equivalent to one hour fire barrier rating.

Install automatically activated fire suppression.

Upgrade perimeter walls, floor, and ceiling to one hour fire rating.

i 4 In some fire areas, upgrade per'imeter walls, floor, and ceiling to three hour rated barrier and installing three hour fire dampers and doors. ~

There are sor,"e eighteen (18) fire areas which do not fully comply with Appen-dix R Section III.G. Based on a combination of fire protection modification, ad~inist.ratlve procedural controls and fire hazards analyses, the licensee has requested exemptions. In the even: that the exemptions are not granted, a

'chedule exemption request is included for each of the eighteen fire areas.

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The licensee proposes to make modifications to. support their exemption requests. To a great extent, these backfits depend very heavily on the use of flamemastic as a deterrent to flame propagation. A comparison between the proposed backfit modifications in support of exemption requests and those backfits required in the event that exemptions are denied follows.

8 K@1 tl 01 IC 1 NS 1N SUPP R BACKF1 S R QUIR 0 IN THE EV NT H T OF EXEt'OPTION REQUESTS EXENPTIONS ARE DENIED Cable Tray .Flame Impingement/ Cable Tray Thermal Insulating Wrap Thermal Shields Conduit Thermal Insulating Material Conduit Thermal Insulating Haterial/

Spray N/A Automatic Pire Suppression Fire Dampers Fire Dampers Barri ers, Penetration Seal s, and Barriers, Pe'netration Seals, and Fire Fire Doors Doors/Fire Proofing Fire Detection 1

Part Height Walls, Penetration Fire Detection Seals Valve Operator Fire Barrier One Hour Rated Valve Operator Fire Enclosures Bar rier Enclosures N/A Fire Detection Cable Rerouting Cable Rerouting Alternate Shutdown Control Room and Instrumentation and Control Hodifica-tions Automatic Fire Suppression System Automatic Fire Suppression in Aux.

in Cable Spreading Roon and Control Bldg. Corridor, Cable Spreading Room Building Stairwell and Control Bldg. Stairwell Hain Steam Platform, Feedwater Platform, Fire Pumps Eq;ipnent Fire Barriers/Walls ARB Total =...closure of One Diesel Gener-Diesel Generator Radiators, Curbing ator Radiator with Three Hour Rated Adjacent Diesel Generator Radiators Barriers

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" '4% "5 A review of the fire modeling techniques was conducted and was,found to be,-.";.;- =- -":.

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representative of the present state-of-the-art for the cases outlinedrates,".';-"'.-"-

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Appendix A of the submittal. These include models for heat release stratification, turbulent, buoyant diffusion plumes and radiation.

Appendix A.5 deals with an analytical method for. determining the size of ther-mal shields used to divert hot fire gases from direct 'impingement upon elec- .

trical cable trays. The temperature reduction calculated in the wake of the thermal shield is calculated as bei ng linearly proportional to velocity when in- fact, it is proportional to the square root of the velocity effect. Due to this discrepancy, the calculated temperature in A.5 tends to be more conser.-

vative than warranted.

Appendix B presents an evaluation of the effectiveness of flame retardant cable coati ngs in reducing the damageabi lity of the types of cables used in this plant v,hen they are subjected to exposure fires. This report by Research Corporation concludes that coatings are effective in early Factory'utual staoes of a fire, enhancing energies required for initiating cable jacket de.-,

gradation and piloted ignition to a greater degrei than for auto-ignition and electrical failure. At a stage where a fire is burning at its maximum intens-ity, coatings are expected to have an insigni icant effect on the fire.

The task of reviewi ng and evaluating these modifi cations -.and exemption re-quests is not within the scope of vrork assigned to BHL. However, the follovr-ing comments are offered for consideration.

1.. Auxiliary feedwater pump auto-start circuits for Unit 3, Unit 3 backup, Unit 4, and Unit 4 backup are all contained in fire area 106. Since it appears that a single fire could destroy all these cables, we recommend that the staff request that the reqirements of Section III G.2 and III G.3 be met in this area.

This also applies to control cables for the charging pumps, component cooling water pumps, intake cooling water pumps, boric acid transfer pumps, pressur'izer heater control group and pressurizer heater backup group.

2~ The use of the pressurizer heater A&B backup groups represent the primary I

mode of pressure control. There is no clear indication of the actions which will be taken in the event of total loss of" the pressurizer heater function. This concern was ansvrered during the,telecon~ at which time, the licensee indicated that the safety injection pumps would be used.

Procedures are required which describe necessary operator actions to com-,

pensate for the loss of pressurizer heaters due to h fire.

3. Unit 3 and Unit 4 power and control cables or the'harging pu'ps and diesel generator breakers are installed in fire area 79 switchgear rooms.

The licensee proposes to protect one train with the equivalent of a one hour fire rated barrier. However, an exemption request is made to rvegate the installation of additional fire detection and suppression systems.

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4. The licensee does not intend to provide an alternate shutdown panel for hot or cold shutdown. There are available at various switchgear and motor control centers, isolation devices which will enable the transfer of con----.

trol power from the control room to a local control station. In addition, control stati'ons exist at the Unit 3 and Unit 4 auxiliary feedwater con-trol stations and other locations which were not described in the submit-tal. These systems will be used for hot shutdown. Cold shutdown will be conducted from the control room. There is a request for exemption from installing a fixed fire suppression system in the control room.

2.1.3 Alternative or Dedicated Systems Pro osed Since the licensee stated that they must leave the control room in case of a control room fire, we consider that alternate shutdown is required for this area.

The licensee does not propose to install an alternate or dedicated shutdown .,

panel They i ndi cate .i;ct remote control stat i ons a r e avai 1 ab] e whi ch have provision to control power to equipment which is required for hot shutdown.

In Section 3.).6 of their submittal, the licensee states that should the local and remote control stations, associated with equipment utilized to maintain hot shutdown conditions, become in accessible or lose control power., the equipment can be restarted or tripped at thei r associated power sources.

Equipment fed from the 4160 switchgear can be operated at the associated 4160 V switchgear. Equipment fed by the 480V load centers or 480V motor control centers can also be operated at their respective load center. If reposition of 480V motor operated valves is requi red and the associated YACC supply is out of service, requi red valve operations may be conducted manually.

2.2 Section III-L Alternate and Dedicated Shutdown Capability Com liance 2.2. 1 Performance Goals Hone of the performance goals listed as 2a, b, c, d, and e can be assured for alternative shutdown since the licensee proposes to use remote panels that do not meet the requirements of Section III G.2. Furthermore, no new remote snutdown panels have ever been discussed by the licensee.

The goal of process monitoring is not met since the:licensee does not propose to provide the following i nstrumentation i n case inaccessibility of the con-trol room due to a fire, source range flux monitoring, or storage tank levels.

2.2.2 72 Hour Re uirement The licens=e did no; definitively state i.-. their submittal that cold shutdown conditions can be met in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This concern was addressed during the telecon a which time, the licensee posit',vely stated that this condition can~

be satisfied.

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2.2.3 Procedures and Manpower The licensee has made a number of exemption requests which are affected by the-status of these requests. The final procedures will be forthcoming when final decision is made relative to the exemption requests.

The licensee i ntends to provide emergency operati ng procedures such as opening of ci rcuit breakers, manual operation of valves, and'removing fuses.

During the telecon, the availability of the current procedures for safe shut-down actions in the event of a fire in the control room was discussed. The procedures supplied by the licensee was titled "Emergency Operating Procedure 20005." "Control room inaccessibility" dated April 25, 1980; This procedure i ncorporated some thirty-seven (37) operations which are requi red of the oper-ators inorder to setup the plant for remote operation. The manpower re-quirements to accomplish these actions are not clearly deli neated in the sub-mittal.

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".r concern about pulling of fuses which is considered a repair is discussed in 2.2.5.

The licensee stated that no repairs were planned for post fire shutdown.

2.2. 5 Associ ated Ci r oui ts and Isolation The licensee proposes to pull fuses to close the PORV's, main steam isola-tion valves and steam generator blowdown valves. This is unacceptable be-cause Appendix R precludes the use of repairs during hot shutdown, and the pulling of fuses is considered a repai r.

This concern was addressed during telephone conference with FPKL and NRC which occurred on August 17, 1982. At that time the licensee indicated that the pulling of fuses would be an action of last resort and would only be initiated should all efforts to isolate the valves fail.

The licensee has satisfactorily addressed associated circuits of concern.

They have used the guidance'rovided in the NRC gene'ric letter 81-12 and the subsequent clarification letter dated Hay 10, 1982.

Common Bus Analysis. The licensee has analyzed for common bus concern and conc u es t at a circuits connected to common power sources have coordinated ci rcuit protection. As a result of the telecon, the licensee will submit some schematics which demonstrate that this concern has been addressed.

ip affected by spurious signals has been d h<<1 Spurious Sign=-1 Analysis. The licensee states that all power, i nstru ient, and traced throughout i

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power los plant to identify the cable unctions routed through each fire area. The analysis was conducted as follows:

a. De~eloped table listing all power supplies for instrument, control, and power cables.

b. Reviewed the power supplies to assure that each connected circuit had c> r-cuit protection.

c. Location of protective device for qach circuit was evaluated relative to the location of the protective device of shutdown circuits and circuits required to mitigate the consequences of a fi re.

lilith regard to equipment whose spurious operation could impact safe shutdown capability on violate high/low pressure interface, the licensee has treated these circuits identically to the circuits required for safe shutdown. All circuits in this category have been identi ied as "equipment required to miti-gate the consequences of a fire" and are discussed in Section 3.3 of the sub-ittal and analyzed similarly to safe shutdown circuits. Emergency safety fea-ture actuation signals were also reviewed and'nalyzed.

The licensee proposes to utilize the folic.;irg m=thoas to di "ab'.e equipment which is being cycled by spurious signals:

Open circuit breakers, Lock di sconnect switch open,

.Remove fuses, Close associated b]ock valve, and Shutdown pumps.

Some examples which demonstrate the use of the above methods are:

VALVES l<ETHOO tiOV 3/4 - 751 Disconnect locked open PCV 3 - 455C Close associated block valve additionally remove fuses.

POY 3/4 - 2604 Remove fuses PCV 3 - 455A Secure reactor coolant pumps additionally open associated circuit breakers.

Valves such as POY 3/4 - 2604 are required for hot shutdown. In instances such as thi s, the pulling of fuses duri ng hot shutdown is considered a repair and as such is unacceptable in accordance with Appendix R.

Common Enclosure. This concern was analyzed from two perspectives.

1. Does the ci rcuit have ci rcuit protection?

2. i>ill the circuit allow fire spread frow one fire area to another?

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9 s i The licensee concluded that associated'circuits that share a common enclosure;:,.--; -,,'.

with safe shutdown cables are not a concern because all power, control, and instrumentation circuits are electrically protected..In addition, all'ir- 'he ".

cuits are fire sealed where they .penetrate walls, floors, and ceilings.

only associated of concern, subsequently, are those associated with to mitigate the consequences of a fire. equipment'equired In addition to determining circuits to be reviewed with the safe shutdown. ci'r=.:. =';..-,

cuits, the licensee took the position that should. the 3/8" sample valves for the RCS inventory be left open that the resultant loss is well within the capacity of the charging pumps.

2.2.6 Hiqh/Low Pressure Interface licensee has addressed this concern via the associated circuits review .i n,

'he 3.3 of the submittal. This concern has been satisfactorily addressed 'ection wi"h the exception o> fuse pullfng during hot'hutdown.

OP=M IT"HS

1. The licensee has not demonstrated that any of the basic performance goals (2a, b, c, d, and e) can be met for alternative safe shutdown around the control room (see 2.2.1 "Performance Goals" ).

2. The HRC requirement for source range flux monitoring capability during shutdown when the control room is inaccessible is not being met.

3.'he capability to monitor boric acid storage tank level and RCS cold and hot leg temperatures during shutdown remote from the control room should be demonstrated.

4. The pulling of fuses during hot shutdown is not allowed, therefore,. mod-ification of the procedures to isolate some valves is required.

5. Hanpower,requirements to effect shutdown remote from the control room should be clearly delineated.

6. Where cross connection, piping between Units 384.is being installed in systems such as the charging system, main steam supply to the auxiliary feedwater system, and component cooling water system, the pump discharge piping should be checked to assure that excessive pressure drop does not resul t.

7. The licensee should provide assurance that one train of shutdown cables is protected against fire damage in all areas such as'rea 106 etc. The protection should be in conformance with Appendix R,Section III G.l, 2, or 3 ~

APPENDIX 'A.=

NATIONAL LABORATORY 'ROOKHAVEN M EMORANDUM August 18, 1982 TO: Fil es FROM: H.J. Thomas and E. HacDougall SUB J=CT: Turkey Point Units 3 8 4 - Post fire safe shutdown revievi telecon of August 17, 1982 The Turkey Point review consisted of several documents submitted over a span of two years. The major submittal of July 1, 1982 which is a report entitled "Tur::ey Point Units 3 8. 4, Fire Protection Review"..served as the basis, for the teie=~n he.~ cn august 17, 1982. The participants for this conference v ere as follows:

NP,C V. Panciera - Section Leader, Auxiliary Systems Branch D. I'.acDonald - Project Manager R. Gramm Reviewer M. LBFave - Reviewer BNL H. Thomas - Reviewer E. I',acDougal 1 - Reviewer LICENSEE J. Burford - FPKL S. Hill - FP&L J. Hayes - FP8L P.. Case - FPSL J. Purcell - FPKL A short discussion as to'he status of the exemption requests by FP8L preceded the responses to the prepared questions which constituted the basis for the It v(as clarified that the exemption requests are handled by the 'elecon.

Che~.ical Engineering Branch and consequently were not a consideration of this con erence. The licensee's responses should therefore be based on the assump-tio-. that the exemption requests v.'ould be granted, b ". that thi s revi ew would not constitute any determinations as to the exemptiors. The follov:ing is arra".ged in the question and answer format used during the conference.

il BHL: 4'here are the isolati'on switches and remote control stations phys-ically located?

LICENSEE: After stating that the present control mode for safe shutdown, does represent a form of alternate shutdown;, the licensee indicated that the isolation switches were located at the following locations.

4160 Volt 4A Switchgear Room 4160 Volt 4B Switchgear Room Load Center Room Locati on, Uni t 4 (So..l/al 1 )

liCC4A - North End Location Cable Spreading Room Location D.C. S>>itchgear Room Location The. licensee was not sure whether this listing represented the most cur-rent information since it >>as compiled in June '980. They are to re-check and obtain the most current listing and forward to HRC - BhL.

This will be reviewed at an upcoming mee i ng. Remote stations are located ai the following locations:

Unit 3 Auxiliary Feedwater Control Station Unit 4 Auxi'liary Feedwater Control Station and elsewhere - information to be provided at upcoming meeting.

4 BHL: l.'hat systems are controlled from the,:remote panels?

LICENSEE: Some of the processes which are controlled. are:

Auxi.l i ary Feedwater Pressurizer Level Bo rat i.on BHL: Asked the licensee which systems are to be used in the event that the pressurizer heaters are lost?

LICENSEE: Safety injection.

BHL: When the control roan is not available, is the following informa-tion available?

Heutron Flux Auxiliary 'Condensate Flow RCS Cold and Hot Leg Tenperatures L'C  !'CSEE: Ho, foi neutl on flux. The additional .informati on wi1 1 be provided through correspondence.

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4. BHL: Are tank level indications available for all tanks which are proposed for use during shutdown such as:

Boric Acid Stora'ge Tank Primary Hater Storage Tank Refueling Hater Storage Tank Spent. Fuel Storage Tank LICEllSEE: The primary tank which is proposed for boration is the boric acid storage tank.

BNL: Is there sufficient capacity of boric acid in this tank to satisfy the boration needs to achieve cold shutdown condition?

ICENSEE: If additional boration is required, then the refueling water storage tank or the spent -fuel storace tank is available.

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"..NL: Hher will procedures to effect safe shutdown in the event o,,i, e in the contlol roc'e available?

NRC: Does the 1 i censee have them and can they prov i de by ma i 1?

LICENSEE: Yes.

6. BNL: Are col d Shutdown condi ti ons achi evabl e wi thi n 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />?

LICENSEE: Yes.

7. ~ BHL: Are isolation switches HEPTA, UL or ANSI rated?

LICEliSEE: Does not know, however, they would not attempt to degrade the quality of instal led devices. If, anything, they would try to improve on the quality. They will recheck.

8. 'BflL: Hhat is done to assure that the, isolation swi,tches are properly matched to the connected load?

LICENSEE: They certainly'ould not purposely overload a switch or de-vice and make every effort to take voltage, current, temperature, and environmental condition into consideration.

9. BHL: Hhen modifications to existing systems are required, do replace-'ent i sol ation devi ces have the same level of qual i ty?

LIC"-."SEE: Equivalent or bet.er.

10. BllL: Pulling fuses is proposed for so'e valves such as VISV POV-4-2604, PO'!-3-2604, etc. NRC believes that fuse pul in 9 for 1 D.C. ci rcui ts dur - <

ing hot shutdovn should not.be allow=d. Further discussion during a conference is desirable.

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LICENSEE: They have based their 'fire protection design on the belief that there will not be any cable damage because of the precautions that have been taken they are protecting both trains of shutdown cables in most cases. They have analyzed spurious operation of valves during a fire. Should valves or pumps. be operated .spuriously, they postulate that there will be sufficient time to allow for analysis and evaluation of the phenomena. They will try,all corrective action possible prior to pulling fuses. Pulling fuses will be a last resort operation.

BNL: Can licehsee provide electrical el ementaries which describe alter-nate shutdown provisions at the remote panels and six emergency control stations? Elementari es which depict isolation devices in various cir-cuits are desirable.

LICENSEE: Yes.

12. BNL: Can licensee provide schematics of mechanical systems required for'afe shutdown?

L IC. NSEE: Yes.

IhPROliPTU QUESTIONS A. BNL: Cross ties are installed for charging system, component cooling water system, steam supply to auxi liary feedwater pumps. Has the piping in these systems been checked to assure that flow'ivill not be restricted because of pressure drop when supplying the needs of Units 364?

LICENSEE: Yes B. BHL: Are there any repairs postulated v

for hot or cold shutdown?

LICENSEE: None C. BNL: Are there any motor driven auxiliary feedwater pumps?

LICENSEE: Two are proposed for installation in their exemption re-quests.

BNL: Are there any control interlocks such as 1'imit switches which will inhibit the ability to achieve safe shutdown?:

4 LICENSEE: 'klill check. C The licensee sugcested that a face to face meeting be arranged at which time e< oris will be made to resolve all quest lons Ther: ~ L"as Qeneral agreement be'.v een all parties, and NRC will arrance a meeting.

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